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(8) Very little personal information is contained on these records as indicated in the attached memorandum and printouts showing the data card layout. Very little is required beyond salary, grade, year of birth, and entry age.

(9) No guidelines have been prepared in connection with these files since they are used primarily for statistical purposes by the Actuary. Copies of the final valuation reports showing the data in these files on a statistical basis (and not by name) are distributed to other agencies with the knowledge and consent of the State Department or D.C. Government as the case may be.

(10-A) Employees contained in this file are not aware that this file is kept in the Treasury Department.

(B) There should be no objection by the State Department or the D.C. Government to anyone looking at the payroll information pertaining to him which is contained on these individual records.

(11) The above data by name would be available to no one except the State Department and D.C. Government who provide us with the basic punched card decks in the first place. Final valuation reports, however, are used by Congress, the Budget Bureau, the State Department, and the D.C. Government in studying the benefits and financing of the systems.

(12) Records have never been used on an individual basis. Therefore, no record has been maintained of such use. The infrequent tabulation runs furnished to the State Department are not particularly recorded. However, the time and date of such runs should be easy to trace.

(13) In the case of the Foreign Service active deck, the basic deck is obtained from the machine data section in the State Department. Entry age information, however, is obtained from the Foreign Service Retirement Section. In the case of the District of Columbia records, these active cards are reproduced directly from their payroll cards and sent to us. Here again, year of birth and entry age are added after they are obtained from the Retirement Section in the District Government.

(14) These records are checked for accuracy only to the extent that the statistical accuracy is affected. Individual accuracy is not vital so long as unreasonable items do not appear.

(15) As stated above, no other agencies except the State Department and the District of Columbia Government have access to the information in this file.

(16) States or other Federal agencies do not use or have access to this file. (17-A) Only authorized persons have access to the punched card file. It is kept in an area with other punched cards which has limited employee access. Printouts are kept in a safe.

(B) To our knowledge, there is no improper use of the information.

(18) Up to this point the question of formal or informal arrangements with congressional committees has not arisen.

(19-A) Because of its purely statistical use, this set of records has not been discussed before any congressional committees by Treasury representatives. (B) Not applicable.

(C) Not applicable.

Attachments

The following attachments which were submitted by the Office of the Secretary along with the office's response appear below:

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The Secretary of the Treasury shall prepare the estimates of the annual appropriations required to be made to the Fund, and shall make actuarial valuations of such funds at intervals of five years, or oftener if deemed necessary by him.

The Secretary of State may expend from money to the credit of the Fund an amount not exceeding $5,000 per annum for the incidental expenses necessary in administering the provisions of this subchapter, including actuarial advice. Aug. 13, 1946, c. 957, Title VIII, § 861, 60 Stat. 1024.

Library references: United States 40; C.J.S. United States §§ 38-40.

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§ 31-716a. Estimates of annual appropriations-Actuarial valuations. On and after July 31, 1953, the Treasury Department shall prepare the estimates of the annual appropriations required to be made to the teachers' retirement fund, and shall make actuarial valuations of such fund at intervals of five years, or oftener if deemed necessary by the Secretary of the Treasury, and the Commissioners are authorized to expend from money to the credit of the teachers' retirement fund not exceeding $5,000 per annum for this purpose, including personal services. (July 31 1953, 67 Stat. 279, ch. 299, § 1.)

PART III-BUREAU OF ACCOUNTS

The Bureau of Accounts submitted responses regarding two sets of data banks: recurring monthly payments files and miscellaneous files. These are presented and analyzed separately in the two subparts below.

Subpart 1-Bureau of Accounts Recurring Monthly Payment Files

Subcommittee Analysis

The Bureau of Accounts reported four "Recurring Monthly Payments Files."

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(VA) 1. Provides information necessary for issuance of 6,500,000.
monthly payment checks.

(2) Identification data, amount payable to re-
cipient.

B. Social Security Administration files (SS) (1) Provides information necessary for issuance of 24,000,000. (computerized)

monthly social security checks.

(2) Same as in A above.

C. Civil Service Commission files (CSC) (1) Provides information necessary to issuance of 1,000,000.
(computerized)
benefit payments authorized by Civil Service
Commission.

(2) Same as in A above.

D. Public debt files (PD) (computerized)... (1) Provides information necessary for issuance of 400,000.
bond interest payments authorized by
Bureau of the Public Debt.

(2) Same as in A above.

II. Nature of Material Submitted

In general, the Bureau of Accounts response regarding Recurring Monthly Payments Files was straightforward. However, as indicated below, responses to items 11 and 17 contradict one another.

III. Comments

A. Statutory Authority

5 U.S.C. 901 generally charges the President with the task of examining the administration of executive agencies and making such changes as are necessary to promote efficiency. Executive Order 6166 was issued pursuant to the legislation, and transferred the function. of "disbursement of moneys by any agency" to the Treasury Department. The maintenance of records is clearly implied by the nature of the Order, the statutory authorization for which is itself implied. B. Subject Notification and Review

Subject individuals are not notified of their inclusion in the files, but could gain access to information by specific request. Additions, deletions, revisions of data are made only at the direction of the authorizing agency.

C. Access by Other Agencies

Response indicates that only the agency authorizing payment has access to information in the files.

D. Public Access

Answers to question 11 state that no information from any of the four files is made available to outside individuals. However, the replies to question 17 state that records would be revealed to ". the individual himself or to one having a vested interest in the information."

E. Security Precautions

Response indicates only that records are stored in a secured area. No guidelines or procedures have been issued regarding security of, access to, or disclosure of information.

F. Sources of Information

Information is provided to the Department of the Treasury by the authorizing agency.

IV. Evaluation

The absence of guidelines governing security of records is disturbing, as is the provision of data to parties having a "vested interest" in it. However, the information contained in disbursement files is not such as warrants elaborate and expensive controls.

Agency Response

The following Bureau of Accounts responses to the subcommittee's October 15, 1971 request for replies to the subcommittee's standard questionnaire (see inside back cover), were prepared November 16, 1971. They were not received by the subcommittee until May 8, 1973.

BUREAU OF ACCOUNTS

A. MASTER FILE (VA)

Date Response Prepared.-November 16, 1971

Class of File.-All Other Files 1

File Control No.-01

File Medium.-Magnetic Tape

National Security Classification.-None

(1) Describe briefly the major categories_of data on individuals presently maintained and stored under auspices of the Treasury Department and its agencies and the approximate number of subject individuals covered in each category.

Disbursing offices under the Department of the Treasury maintain master files for the issuance of recurring monthly benefit payments authorized by the Veterans Administration. The master file consists of magnetic tapes containing payee records which include the name, address, account number, and amount paid to each recipient on a monthly basis. Using information supplied by the authorizing agency, the file is updated monthly to delete or add records or change information on existing records. A check is issued to each payee from the magnetic tape record on the monthly updated file. There are approximately 6.5 million individuals represented on this file. (2) Under what statutory and administrative authority was each data bank established and for what purpose? Please supply copies of pertinent federal statutes, regulations and memoranda on which this authority is based and by which it is implemented.

1 A miscellaneous classification, as opposed to "Government Employees," "Law Enforcement" and the like.

Disbursing authority was established by Executive Order No. 6166, S4 dated June 10, 1933. (5 U.S.C. 901 nt.) Authority to use automatic data processing equipment and methods was established by Treasury Department Administrative Circular No. 73, dated June 27, 1962. [See Attachment 1] (3) Are Treasury Department controls, guidelines, or advice required by or offered to state officials and private individuals who either administer or who utilize this data-gathering program? Please supply copies of pertinent rules or advisory documents as issued by federal and state agencies.

No.

(4) For each category and each conglomerate of data, indicate its present stateof computerization or other mechanization for access and retrieval as well as for evaluation and analysis.

The master file is a simple reel of magnetic tape with recorded payment data. There are no sophisticated systems for access and retrieval of information. It is possible to mechanically search the tape to find a particular record. The data consists of complete payee records (as mentioned in No. 1 above), but is not of a nature which lends itself to evaluation and analysis. (5) Describe plans for further computerization or mechanization in each program.

None.

(6) In what instances would each system be utilized? By what officials and by what agencies?

Not applicable.

(7) For each new data storage and processing program, please describe: (a) the advantages; and (b) the extent to which it permits correlating, common storage and multi-faceted analysis of data on a scale not hitherto available.

Not applicable.

(8) What specific subject areas concerning an individual's background, personal life, personality and habits are noted in each data program?

None.

(9) Has the Treasury Department and its component agencies developed comprehensive guidelines governing maintenance of any or all the various data systems, access to them, review and disclosure of material in them, and distribution of data to other agencies? If so, please supply copies.

No.

(10-A) Is the subject individual or his representative notified of the fact that he is in the data bank?

The individual is not notified automatically that informatio n abouthim is in the data bank. (B) Is he allowed to review the data on record about him; to supplement his file; or to explain or rebut inaccurate material? Please describe the precise limita-tions on such rights for each restriction.

Data is changed upon individual's notification to authorizing agency which determines need for change.

(11) What aspects of the recorded data are available to other persons? Who, specifically? For what purpose? By what authority?

None.

(12) Is a record maintained of each inspection or use of the individual's record? A microfilm record is maintained of each month's use. (13) For each data bank, please indicate how the information is collected, whether it is solicited from the individual, from third persons, or from existing records.

Initial information is received from the authorizing agency. Its source is the individual or his representative.

(14) What officials in your agency are responsible for determining the accuracy of information in the data bank? What provisions are made, procedurally, for deleting information found to be inaccurate or inappropriate, either on the initiative of the agency or on motion of the individual?

None. Accuracy is the responsibility of the administrative agency serviced. (15) What other agencies have access to information or use of information in each data bank?

Only the agency which supplied the information has access to it.

(16) What states and federal agencies may utilize the data in your computerized files by coding, interfacing and other devices relating to their own computers? None.

(17) What security devices and procedures are utilized to prevent: (a) unauthorized access to the data file; and (b) improper use of the information?

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